The Rt. Hon Ian Lang MP President of the Board of Trade Department of Trade and Industry 1 Victoria Street London SW1H 0ET 25th March 1997

On Christmas Eve last year you invited interested persons to apply for oil production licences for an area of over 22,000 square miles of the Atlantic Ocean. I am writing on behalf of Greenpeace Ltd to express an interest in these licences. We attach a copy of our application for all 275 blocks of the UK Continental Shelf 17th Round of Licensing which we have delivered to the DTI Exploration and Licensing Division. We are asking you to consider this letter as integral to the justification and reasoning of our application.

We seek to be considered as operators and guardians of the licence area. On the basis of information available to us from the Intergovernmental Panel on Climate Change, and the primary objective of the Framework Convention of Climate Change, which is to prevent dangerous interference with the climate system, we are firmly of the view that there is currently no justification for extracting oil from this area, and that our duty of care requires an operating regime of non-intervention. We have outlined an extensive work-plan for the area which will, for the first time, give us an overview of the natural diversity of the region.

We hope that, as outlined in your official announcement, you will judge our application 'against the background of the continuing need for expeditions.... and with due regard to environmental considerations'.

We believe that the question of 'need' should be at the heart of your decision on the licensing of this area of the Atlantic Ocean since it has profound implications for the global environment.

The greatest implications for you to consider are the effect such development has on our ability to control the rate of climate change in the next century, via the expansion of fossil fuel supply. A simple analysis of carbon cycle models indicates that we cannot avoid dangerous rates of increase of temperature and sea level if we extract and burn all known reserves of fossil fuels.

Your government has made a commitment to preventing dangerous climate change. To do this the rate and magnitude of temperature and sea-level rise must be reduced and/or limited. The European Union has set a policy objective to keep global mean temperature rise below 2 degrees Celsius above pre-industrial levels. This temperature has been identified by UNEP as "an upper limit beyond which the risks of grave damage to ecosystems, and of non-linear responses are expected to increase rapidly". It should therefore be seen as a limit that must be avoided by a significant margin.

This effectively imposes a carbon 'budget' on the world, and allows us to calculate exactly how much carbon can be emitted over the next century. We know for example that if the climate has a relatively high sensitivity, and we are to avoid a 1 degree Celsius change over the next 100 years, that we have to return carbon dioxide concentrations to approximately 330ppm. This would allow a total world-wide carbon budget of 225 billion tonnes of carbon. Even if we adopted the inherently riskier EU target of a maximum 2 degree Celsius rise, rather than the precautionary 1 degree Celsius target , and assume that the climate is less sensitive to the effects of CO2, the total carbon budget is still only 585 billion tonnes of carbon. This is considerably less than the fossil fuel resources currently earmarked as 'economic' reserves which currently stand at over 1000 billion tonnes of carbon.

The rub is that whichever of the two approaches is adopted the quantity of carbon that the atmosphere can absorb is less than the quantity of carbon locked up in identified and 'recoverable' fossil fuel reserves. In fact, for the 'risky' EU objective the carbon budget allows for the burning of only half of 'recoverable' reserves, and less than 15% of the likely total below ground resource for coal, gas, and oil. The inescapable conclusion of this climate logic is that the overriding need for UK energy and industrial policy, just as for other industrialised countries, is to ensure that most oil, coal and gas remain below the ground, and to promote investment in the alternatives to fossil fuels.

At current rates of consumption and fuel mix the world will exceed a 1 degree carbon budget in under 40 years. In fact, rates of fossil fuel use are increasing throughout the world and therefore a complete halt will be necessary much sooner.

If a phase out is started now it would be possible to gain time for the transition from fossil fuels to a solar economy. A rational response to the problem would be to phase-out coal use rapidly, stop the exploitation of non-conventional fossil fuels, and stop all oil exploration and production in new oil fields. Greenpeace has called on the EU Presidency to enact such a policy across member states. It is clear that whatever menu of policy instruments are adopted by governments to balance the carbon budget it is highly unlikely that there would ever be any need to open up a major new zone of oil development on the Atlantic Frontier. Greenpeace would be happy to discuss the basis of our non-interventionist management of the license area in the context of any Government policy on fossil fuel phase out.

The Greenpeace application for a production licence for non-intervention is intended to help achieve the main objective of the Framework Convention on Climate Change of stabilising "greenhouse gas concentrations in the atmosphere at a level that would prevent dangerous anthropogenic[human-made] interference with the climate system." Greenpeace also seeks to take regional and local environmental considerations into account. Initial research we have conducted in the light of this application suggests that the importance of the Atlantic margin for deep sea life forms is high. The work-plan presented in our application outlines our intention to conduct an extensive survey of marine mammals in the licence area.

We suggest that in addition to approving non- intervention management licences for the Atlantic frontier that the Department of Trade and Industry issue licences to increase the productivity of the UK's use of it's above-ground energy resources, namely solar, wind, biomass and wave power. At present the UK has the lowest 'solar productivity' of any EU nation, measured as a percentage of our electricity consumption provided by renewable power. Greenpeace will work with any industry and with any Government genuinely committed to maximising the exploitation of renewable solar resources in the UK.

Although there has been no debate within Government about the implications of a finite carbon budget for the fossil fuel industry we believe that your decision on the future development of a large swathe of the Atlantic Ocean is the time to start that debate. It will be a decision of historic importance. We would be happy to provide more detail about the science and analysis that we have used for our application.

If you reject our application and allow the oil industry to open up new deep sea reserves of fossil carbon you will be unleashing an enormous expansion of the oil industry in Europe, with implications for frontier marine environments around the world, and for the expansion of fossil carbon reserves in other regions. Last year, in correspondence with Greenpeace, John Major stated that "We do not accept the argument of those, including oil and coal producers, who deny climate change or claim that their financial interests should be put first" . We would urge you to heed these views, to redirect your industrial programme to raising the solar productivity of Britain by encouraging investment in renewable energy, and to leave the Atlantic Ocean to the wind and the whales.

Yours sincerely

Chris Rose Deputy Executive & Programme Director Greenpeace UK

Official Journal of the European Communities: 24.12.96

UNEP Advisory Group on Greenhouse Gases: Rijsberman and Swart: 1990

Assuming 3.5 degrees Celsius sensitivity, that other greenhouse gases contribute 23% of the CO2 forcing, and that there is no net contribution from deforestation/reforestation.

that is 2.5 degrees Celsius

IPCC Conventional and Unconventional Reserves Identified/Potentials by 2020-2025 = 1,053 GtC and IPCC Resource Base Maximum Potentials = 4,166 GtC

Currently Fossil carbon released = 6 GtC/yr.

Share of renewable energy sources in gross inland consumption: UK =0.6% EU average = 5.4%: source :EUROSTAT quoted in European